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Decoding LCRI: Exploring How Technology can Help with Compliance

December 7, 2023
4
Min Read
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The use of lead pipes was banned in the 1980s, yet over 9.2 million American households still connect to water through lead pipes and lead service lines. These decades-old lead pipes pose an ever-present risk to the health and wellbeing of Americans. The unfortunate reality is that there is no safe level of exposure to lead. It can harm children as well as adults, and cause consequences that would be hard to avoid. The proposed Lead and Copper Rule Improvements (LCRI) is a solution to this concern and presents a once-in-a-generation opportunity to improve our water infrastructure with a positive impact on community health and wellbeing. Let’s dive a little deeper.

The LCRI Essentials

On November 30, 2023, the Environmental Protection Agency (EPA) published the LCRI — a proposal to strengthen its Lead and Copper Rule (LCR). LCR, published in 1991, established a maximum contaminant level goal (MCLG) of zero for lead in drinking water and a treatment technique to reduce corrosion of lead and copper within the distribution system. Then came the Lead and Copper Rule Revisions (LCRR), with the requirement of science-based testing protocols, requiring water systems to identify and make public the locations of lead service lines, and the need to prepare and maintain an inventory of service line materials.

To further eliminate lead from drinking water, EPA released the proposed LCRI, which requires water utilities to replace lead service lines within 10 years, and thus help secure safe drinking water for communities across the country. The Bipartisan Infrastructure Law devotes over $50 billion for the largest upgrade to the nation’s water infrastructure in history. This includes $15 billion dedicated to replacing lead service lines, providing technical assistance to communities, and supporting the development of a national inventory of lead service lines, and $11.7 billion dedicated to general Drinking Water State Revolving Funds, which can also be used for lead service line replacement. The LCRI is expected to be finalized and implemented by October 16, 2024 following a 60 day initial public comment period.

Key LCRI provisions include:

  • Locating legacy lead pipes
  • Replacing 100% of lead pipes within 10 years
  • Improving tap sampling
  • Lowering the Lead Action Level from 15 µg/L to 10 µg/L
  • Strengthening protections to reduce exposure
  • Requiring water systems to complete comprehensive and publicly available lead service line inventories

The proposal also requires water systems to communicate more frequently with consumers and keep them informed about lead service lines and the system’s plans for replacing the lines.

Technology can Assist with LCRR/LCRI Compliance

Trinnex’s leadCAST, a SaaS technology, is developed to help utilities navigate the regulatory landscape of the LCRR. The leadCAST team has been tracking the LCRI since it was announced by the EPA, and has already begun work to enable our utility partners to be fully compliant with it.

Here’s how leadCAST can help utilities comply with the asks of LCRI.

100% Lead Replacement within 10 Years

leadCAST is well-positioned to help water utilities execute their LSL replacement plans by:

  • Allowing easy movement of properties from the lead inventory into the replacement pool
  • Tracking and visualizing LSL replacement progress
  • Streamlining right-of-entry form collection and management with a public portal
  • Providing in-app replacement inspection capabilities accessible on mobile devices along with inspection QA/QC functionality
Improving Service Line Inventories

LCRI requires annual inventories, and these inventories should record statistics on lead replacements completed each year. Utilities will also need to identify the materials of all unknown service lines within the 10-year replacement period.

The inventory functionality of leadCAST is robust and poised to meet the demands of the LCRI as:

  • leadCAST was developed originally with LCRR inventory compliance at the forefront. The application has a robust inventory management system, which allows utilities to easily understand LSL materials in their inventory.
  • The leadCAST inventory system has functionality for capturing connectors (AKA goosenecks) in addition to service line materials.
  • leadCAST’s inventory system stores documentation such as photos, inspection logs, and includes an audit trail allowing utilities to track changes over time.
  • The leadCAST public map and secure portal enables utilities to easily publish information and communicate with their customers.
  • leadCAST Predict coupled with the field inspection application satisfies the proposed validation process of randomly verifying enough sites to satisfy the 95-percent confidence interval.
Improved Sampling and Public Transparency

Sampling and public notifications are modified by the LCRI to reduce exposure to lead and increase public trust. leadCAST has significant sampling program management capabilities and public notification and communication tracking to aid in this. Some highlights include:

  • A partnership with SimpleLab to provide sampling kits through the leadCAST application to consumers. This integration allows leadCAST users to quickly receive, visualize, and manage sampling programs.
  • Real-time sharing of sampling results with consumers through electronic notifications and the public portal.
  • A direct and verifiable method for consumers, provided by leadCAST’s customer portal, to contact their water utility while logging the communication for compliance with the LCRI including tracking the number of outreach attempts.

While utilities certainly face a challenge ahead, they have access to tools that will help guide them along this journey. This solution not only simplifies the job for water providers, but also plays a crucial role in expanding access to clean and safe water resources for a substantial number of households, contributing to overall public health and well-being.

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Written by
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Mark Zito, GISP
Product Leader | Senior Solutions Consultant
|
He/Him
Mark has over 15 years of experience in geospatial data science and is an expert in Lead & Copper Rule software, including leadCAST.

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